Moorehouse v Governor of Wheatfield Prison & Ors (Unapproved) (Rev 1) [2020] IESC 59 (28 September 2020)

Moorehouse v Governor of Wheatfield Prison & Ors (Unapproved) (Rev 1) [2020] IESC 59 (28 September 2020)

Where a plaintiff is found to be honest but unreliable as to the precise mechanism of an accident, and the evidence otherwise establishes that the defendant's negligence caused the injury, the court is entitled to infer causation and find liability in negligence against the defendant.

Citation
[2020] IESC 59
Parties
Plaintiff/appellant: Felix Moorehouse; Defendant/respondent: Governor of Wheatfield Prison; Defendant/respondent: Minister for Justice, Equality and Law Reform; Defendant/respondent: Ireland; Defendant/respondent: Attorney General
Jurisdiction
Ireland
Judgment Date
28 September 2020
Procedural Posture
Civil Appeal / Appeal From High Court Judgment
Outcome
appeal allowed
Legal Topics
Causation, Negligence, Burden of Proof, Inference of Causation, Statutory Duty
Tort Law Personal Injury Causation Negligence Burden of Proof Inference of Causation Statutory Duty

Case Brief

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Parties

Felix Moorehouse

Plaintiff/appellant

Governor of Wheatfield Prison

Defendant/respondent

Minister for Justice, Equality and Law Reform

Defendant/respondent

Ireland

Defendant/respondent

Attorney General

Defendant/respondent

Procedural Posture

Civil Appeal / Appeal From High Court Judgment

Legal Issues

  1. 1 Whether a court may infer causation in a personal injuries action where the plaintiff's account of the accident is rejected but other evidence establishes negligence and injury
  2. 2 Whether the plaintiff discharged the onus of proof in the circumstances

Ratio Decidendi

Where a plaintiff is found to be honest but unreliable as to the precise mechanism of an accident, and the evidence otherwise establishes that the defendant's negligence caused the injury, the court is entitled to infer causation and find liability in negligence against the defendant.

Court Disposition

appeal allowed

Orders

  • Order quashing the dismissal of the plaintiff’s claim
  • Matter remitted to the High Court to be resumed and progressed to a conclusion